HomeMy WebLinkAbout16-009RESOLUTION NO. 16-009
A RESOLUTION AMENDING THE INVESTMENT POLICY
FOR ST. LUCIE COUNTY, FLORIDA; BY FURTHER
AMENDING THE INVESTMENT POLICY
WHEREAS, the Board of County Commissioners of St. Lucie County, Florida, has made the
following determinations:
1. Pursuant to Section 218.415, Florida Statutes, on or before October 1, 1995, counties
that have custody of public funds in excess of the amounts needed to meet current expenses who elect
to conduct investment activity themselves rather than depositing these funds in the Local Government
Surplus Funds Trust Fund for investment by the State Board of Administration, are required to conduct
such investment activity in accordance with a written investment plan and an investment policy adopted
by the Board of County Commissioners or in the alternative to invest in specified low-risk instruments.
2. On September 26, 1995, the Board adopted Resolution No. 95-168 which adopted an
investment policy as recommended by the Investment Subcommittee of the St. Lucie County Citizens
Budget Review Committee.
3. On December 6, 1995, the Investment Committee recommended that the Board adopt
certain amendments to the investment policy; and on January 2, 1996, the Board adopted Resolution
No. 95-275 which amended the investment policy and incorporated the recommended changes of the
Investment Committee.
4. The Board has previously amended the policy and plans to further amend the policy in
the future.
NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of St. Lucie County,
Florida:
1. This Board does hereby adopt the amendments to the investment policy attached
hereto and made a part hereof as Exhibit "A," pursuant to Section 218.415, Florida Statutes.
2. Except as amended herein, the remaining terms and conditions of the Investment
Policy, as amended, shall remain in full force and effect.
3. This resolution shall take effect on adoption.
After motion and second, the vote on this resolution was as follows:
Chairman Kim Johnson
AYE
Vice Chairman Chris Dzadovsky
AYE
Commissioner Tod Mowery
AYE
Commissioner Paula A. Lewis
AYE
Commissioner Frannie Hutchinson
AYE
PASSED AND DULY ADOPTED this 15th day of March 2016.
ATTEST:
BOARD OFC NTY COMMISSIONERS
ST. LUCIA CO)NTY, FLOODA
BY:
DEPUTY CLERK HAIRMA
APPROVED AS TO LEGAL FORM AND
CORRECTNESS:
A,,sa,x COUNTY ATTORNEY
ST. LUCIE COUNTY BOARD OF COUNTY COMMISSIONERS
INVESTMENT POLICY
TABLE OF CONTENTS
I. SCOPE..................................................................................................................................2
II. INVESTMENT OBJECTIVES................................................................................................... 2
III.
1
IV.
INVESTMENT PERFORMANCE AND REPORTING.............................................................
2-3
COUNTY.
PERFORMANCE MEASUREMENT....................................................................................
3-4
VI.
PRUDENCE AND ETHICAL STANDARDS............................................................................4
F
L
O
R
I D AL
MATURITY AND LIQUIDITY REQUIREMENTS....................................................................6
§
SIX.
PORTFOLIO COMPOSITION.....................................................................................
6-10-5--9
IX.
RISK AND DIVERSIFICATION...........................................................................................108
XI.
-A
ST. LUCIE COUNTY BOARD OF COUNTY COMMISSIONERS
INVESTMENT POLICY
TABLE OF CONTENTS
I. SCOPE..................................................................................................................................2
II. INVESTMENT OBJECTIVES................................................................................................... 2
III.
DELEGATION OF AUTHORITY.............................................................................................. 2
IV.
INVESTMENT PERFORMANCE AND REPORTING.............................................................
2-3
V.
PERFORMANCE MEASUREMENT....................................................................................
3-4
VI.
PRUDENCE AND ETHICAL STANDARDS............................................................................4
3
VII.
AUTHORIZED INVESTMENTS.....................................................................................4-6
-3-&
VIII.
MATURITY AND LIQUIDITY REQUIREMENTS....................................................................6
§
SIX.
PORTFOLIO COMPOSITION.....................................................................................
6-10-5--9
IX.
RISK AND DIVERSIFICATION...........................................................................................108
XI.
AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS ......................................
10-119
XII.
THIRD PARTY CUSTODIAL AGREEMENTS.......................................................................11.9
XIII.
MASTER REPURCHASE AGREEMENT........................................................................
115-48
X41V.
BID REQUIREMENT.................................................................................................48-11-12
XIV.
INTERNAL CONTROLS.............................................................................................44-12-14
Revised on January 26, 2016
I. SCOPE
This investment policy applies to all surplus funds held by or for the benefit of the St. Lucie
County Board of County Commissioners, hereinafter referred to as the County.
These policies were adopted using Sections 125.31 and 218.415, Florida Statutes. Bond
proceeds may be further limited or expanded by their respective bond resolutions or
covenants and shall not be considered to be in conflict with the Investment Policy.
II. INVESTMENT OBJECTIVES
The County shall strive to achieve with each investment opportunity, the following objectives,
in ORDER OF PRIORITY:
1. SAFETY - The primary objective of the County's investment activities is the protection of
investment capital.
2. LIQUIDITY - The County's investment strategy will provide sufficient liquidity such that
cash flow requirements are met through the utilization of marketable securities with
structured maturities.
3. INVESTMENT INCOME - In investing public funds, the County will strive to maximize the
return on the portfolio but will minimize investment risk.
III. DELEGATION OF AUTHORITY
The responsibility for providing oversight and direction in regard to the management of the
investment program resides with the Clerk of the Circuit Court. The Board of County
Commissioners will appoint an Investment Committee that will serve in an advisory capacity
and report to the Board of County Commissioners. Each Commissioner will select one of the
five Investment Committee members who will possess relevant financial experience. The
Investment Committee shall meet quarterly to review the Clerk's investment strategy and
results. The Investment Committee will rely on the Clerk of the Circuit Court, the Finance
Director and their staff for support. The management responsibility for all Board's funds in
the investment program and investment transactions is delegated to the Clerk of Circuit Court
or designee. The Clerk of the Circuit Court or designee shall establish written procedures for
the operation of the investment portfolio and a system of internal accounting and
administrative controls to regulate the investment activities. The Clerk may employ
investment manager(s) to assist in managing some of the Board's investment portfolio. Such
investment manager must be registered under the Investment Advisors Act of 1940.
IV. INVESTMENT PERFORMANCE AND REPORTING
A portfolio report shall be prepared each quarter by the Finance Director or designated staff
member, and be provided to the Clerk of the Circuit Court and appropriate management staff.
The report will also be made available to the Board of County Commissioners and Investment
Committee. The report shall include a breakdown of the portfolio as well as its overall
performance and the current market pricing at month-end.
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A detailed analysis of the investment portfolio will be prepared by the Finance Director and
presented to the Board of County Commissioners and Investment Committee on a quarterly
basis. The report shall include information relating to transactions, market values,
performance and adherence to policy. The Clerk of the Circuit Court is authorized to utilize
an investment accounting service to obtain necessary information. The Board of County
Commissioners will conduct an annual review of the investment portfolio and the investment
policy.
The Board of County Commissioners will appoint an Investment Committee that will serve in
an advisory capacity and report to the Board of County Commissioners. Each Commissioner
will select one of the five Investment Committee members who will possess relevant financial
experience. The Investment Committee and the Board of County Commissioners shall receive
a copy of the portfolio pricing analysis.
The Clerk of the Circuit Court shall be notified immediately upon exceptions from currently
approved investment policies by the Finance Director.
In the event of an emergency situation requiring noncompliance with policy guidelines, the
Finance Director shall attempt to schedule a special committee meeting to discuss the
proposed action. If a special committee meeting is not possible due to time constraints or
scheduling problems, the Finance Director shall individually notify a minimum of three
committee members to obtain approval of the proposed action.
V. PERFORMANCE MEASUREMENT
In order to assist in the evaluation of the portfolio's performance, the Finance Director will
use performance benchmarks. The use of benchmarks will allow the Finance Director to
measure its returns against other investors in the same markets.
A. Investment performance of funds designated as short-term funds and other funds that
must maintain a high degree of liquidity will be compared to the return of the S&P Rated
GIP Index Government 30 -Day Gross of Fees Yield. Investments of current operating
funds shall have maturities of no longer than twenty-four (24) months.
B. Investment performance of funds designated as core funds and other non-operating
funds that have a longer-term investment horizon will be compared to the following
indexes:
1. Bank of America Merrill Lynch 1-3 Year U.S. Treasury/Agency Index
2. Bank of America Merrill Lynch 1-5 Year U.S. Treasury/Agency Index
3. Bank of America Merrill Lynch 1-5 Year Government/Corporate "A" rated or better
index
The appropriate index will have a duration and asset mix that approximates the portfolio
and will be utilized as a benchmark to be compared to the portfolio's total rate of return.
Investments of bond reserves, construction funds, and other non-operating funds ("core
funds") shall have a term appropriate to the need for funds and in accordance with debt
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covenants, but in no event shall exceed five and one-half (5.5) years.
C. The Equities, Mutual Funds and/or exchange -traded funds (ETFs) performance shall be
compared on a quarterly basis to appropriate peer universe benchmarks, as well as
market indices in the equity markets. Examples of benchmarks and indexes that will be
used include the Russell 3000 Index for broad U.S. equity strategies; S&P 500 Index for
large cap U.S. equities, Russell 2000 Index for small cap U.S. equities, MSCI ACWI ex -U.S.
Index for broad based non -U.S. equity strategies. The Russell 3000 Index will be used to
benchmark the U.S. equities portfolio; the MSCI ACWI ex -U.S. Index will be used to
benchmark the non -U.S. equities portfolio.
VI. PRUDENCE AND ETHICAL STANDARDS
The "prudent person" standard shall be used in the management of the overall investment
portfolio.
The Finance Director, and other persons performing the investment function, shall act as a
"prudent person" in accordance with these written policies and procedures, exercising due
diligence and investing in investments authorized by law.
The "prudent person" standard is herewith understood to mean the following: Investments
shall be made with judgment and care, under circumstances then prevailing, which persons
of prudence, discretion, and intelligence exercise in the management of their own affairs, not
for speculation, but for investment, considering the probable safety of their capital as well as
the probable income to be derived.
VII. AUTHORIZED INVESTMENTS
The Clerk of the Circuit Court acting through the Finance Director, or other designee of the
Clerk's office, shall purchase or sell investment securities at prevailing market rates, with a
preference to par bonds or those at a discount. Authorized instruments are as follows:
A. The Intergovernmental Investment Pool rated "AAAm" by Standard & Poor's or the
equivalent by another nationally recognized self-regulatory organization (NRSRO) for a
stable Net Asset Value (NAV) fund. If the stable NAV fund has no rating then the
underlying securities must be either FDIC insured; collateralized under the Florida
Security for Public Deposits Act, Chapter 280, Florida Statutes; or have a long term
rating of "A" or better by a nationally recognized rating agency. For a floating NAV
fund, the minimum rating will be AAf/S1 or the equivalent by a nationally recognized
rating agency.
B. The Florida Local Government Investment Trust, also known as "Florida Trust",
administered by the Florida Association of Court Clerks and Comptrollers and the Florida
Association of Counties.
C. Negotiable direct obligations of, or obligations the principal and interest of which are
unconditionally guaranteed by the United States Government. Such securities will
include, but not be limited to, the following:
1. Treasury Bills
2. Treasury Notes
3. Treasury Bonds
D. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by
United States agencies provided such obligations are backed by the full faith and credit of
the United States Government. Such securities will include, but not be limited to, the
following:
1. Farmers Home Administration
2. Government National Mortgage Association (GNMA)
E. Bonds, debentures, notes of or other evidence of indebtedness issued or guaranteed by
United States Government agencies (Federal Instrumentalities) which are not backed by
the full faith and credit of the United States Government. Such securities will include, but
not be limited to, the following:
1. Federal Farm Credit Bank (FFCB)
2. Federal Home Loan Bank or its district banks (FHLB)
3. Federal National Mortgage Association (FNMA)
4. Federal Home Loan Mortgage Corporation (Freddie -Mac)
F. Non-negotiable interest-bearing time certificates of deposit, money market accounts or
savings accounts in financial institutions organized under the laws of the United States,
doing business and situated in this state, provided that any such deposits are secured by
the Florida Security for Public Deposits Act, Chapter 280, Florida Statutes.
G. Repurchase agreements collateralized by Treasury Bills or Notes having a maturity of two
(2) years or less.
H. Securities and Exchange Commission registered money market funds with the highest
credit quality rating from a nationally recognized rating agency.
I. Corporate Obligations or Corporate Notes of U.S. Corporations with at least two of the
following three minimum ratings: A- by Standard & Poor's, A3 by Moody's, or A- by Fitch.
J. Commercial Paper denominated in United States dollars that is rated, at the time of
purchase, Prime -1 by Moody's and A-1 by Standard & Poor's (Prime Commercial Paper).
If the Commercial Paper is backed by a letter of credit (LOC), the long-term debt of the
LOC provider must be rated A or better by at least two nationally recognized rating
agencies.
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K. Supranational Agencies — Debt obligations issued by multilateral organization of
governments of which the U.S. is a shareholder and voting member, and are denominated
in U.S. dollars, with highest Short -Term or Long -Term rating (A -1+/P-1, AAA/Aaa, or
equivalent). Purchase authorization includes, but is not limited to, obligations of the
following multilateral organizations:
1. International Bank for Reconstruction and Development (IBRD)
2. International Finance Corporation (IFC)
3. European Bank for Reconstruction and Development (EBRD)
4. Inter -American Development Bank (IADB)
5. Asian Development Bank (ADB)
6. African Development Bank (AFDB)
Investment in derivative products is not authorized. For the purposes of this policy derivative
products are defined as financial arrangements whose value are derived from changes in an
underlying variable such as a stock, bond, stock index, interest rate index, currency,
commodity, etc. Derivative investments include, but are not limited to: futures contracts,
options contracts, forward contracts, interest rate swaps, interest rate floor or ceiling
contracts, and linked index investments.
L. Equities, Mutual Funds and/or exchange -traded funds (ETFs) — Equities, shares in open-
end and no-load equity and/or fixed-income mutual funds, and/or ETFs.
VIII. MATURITY AND LIQUIDITY REQUIREMENTS
To the extent possible, an attempt will be made to match investment maturities with known
cash needs and anticipated cash flow requirements. Investments, including investment
pools, of current operating funds shall have maturities of up to five and one-half (5.5) years
except the Corporate Obligations. The maximum length to maturity for Corporate Obligations
or Corporate Notes shall be five (5) years from the date of purchase. The Finance Director
and other persons performing the investment function will provide an appropriate mix of
maturities to maximize the return on the portfolio while minimizing investment risk.
Investment of bond reserves, construction funds, and other non-operating funds shall have a
term appropriate to the need for funds, and in accordance with debt covenants, but shall not
exceed five and one-half (5.5) years, unless permitted by the terms of the bond documents.
Equities, Mutual Funds and/or exchange -traded funds (ETFs) are excluded from the maximum
maturity limitations due to the nature of these types of investments.
A liquidity amount of approximately three (3) months of anticipated disbursements,
excluding bond construction payments or other bond payments made from escrow or trust
accounts, will be kept in relatively short-term investments, These would include the State
Investment Pool (SBA), "Florida Trust", money market accounts and Repurchase Agreements.
V4IX. PORTFOLIO COMPOSITION
The following are the guidelines for investments and limits on security issues, issuers, and
maturities as established by the County. The Finance Director, or their appropriate
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designee, after consulting with the Clerk of Circuit Court, shall have the option to further
restrict or increase investment percentages from time to time based on market conditions.
Purchases of investments based on bond covenant requirements shall not be included in
the portfolio composition calculation. The allowable maximum percentage requirements
should be based on the prior month portfolio ending balance. If the maximum percentage
is exceeded for any reason, corrective action should be taken within 30 days of any notice
of violation to conform the portfolio to the allowable percentages.
The following maximum limits are guidelines established for diversification by instrument:
Authorized Investment- Sector Type
Maximum
Allocation
Individual
Issuer
Limit
Maximum
Length to
Maturity
Rei -We RF'rAe
4G4
NAA
NAA
Florida Trust
35%
N/A
N/A
Intergovernmental Investment Pool
40%
25%
N/A
Certificates of Deposit
40%
10%
2 years
Treasuries
75%
N/A
5.5 years
United States Government Agencies
50%
25%
5.5 years
Federal Instrumentalities (United States
Government Sponsored Agencies)
50%
25%
5.5 years
Pepurchase Agreement
10%
10%
1 year
Money Market Funds
80%
25%
N/A
Corporate Obligations or Corporate Notes
25%
5%
5 years
Commercial Paper
25%
5%
270 days
Su ronational Agencies
25%
10%
5.5 years
Equities, Mutual Funds and/or ETFs
5%
N/A
N/A
A. The Intergovernmental Investment Pool
1. A maximum of 40% of the portfolio may be invested in Intergovernmental Investment
Pool.
2. A maximum of 25% of the portfolio may be invested in any one pool.
..�
NIMMITT
B. The Local Government Investment Trust fund (Florida Trust)
A maximum of 35% of the portfolio may be invested in Florida Trust.
C. Non-negotiable Interest -Bearing Time Certificates of Deposit
1. A maximum of 40% of the portfolio may be invested in non-negotiable interest
bearing time certificates of deposit or savings accounts.
2. The maximum maturity on any certificates shall be no greater than two (2) years from
the time of purchase.
3. A maximum of 10% of the portfolio may be deposited in the instruments of any one
issuer.
D. United States Government Securities
1. A maximum of 75% of the portfolio may be invested in United States Government
Securities which are defined as negotiable direct obligations, or obligations the
principal and interest of which are unconditionally guaranteed, by the United States
Government.
2. The maximum length of maturity of any direct investment in government securities is
five (5) years.
E. United States Federal Agencies
1. A maximum of 50% of the portfolio may be invested in United States Federal Agency
securities which are backed by the full faith and credit of the United States
Government.
2. The maximum length of maturity of any direct investment in Federal Agencies
Securities is five (5) years.
3. A maximum of 25% of the portfolio may be invested in the instruments of any one
issuer.
F. Federal Instrumentalities
1. A maximum of 50%of the portfolio maybe invested in Federal Instrumentalities which
are not full -faith and credit United States Government Agencies.
2. The maximum length of maturity of any direct investment in Federal Instrumentalities
is five (5) years.
3. A maximum of 25% of the portfolio may be invested in the instruments of any one
issuer.
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G. Repurchase Agreements
1. A maximum of 10% of the portfolio may be invested in repurchase agreements with
the exception of one (1) business day agreements and overnight sweep agreements
which may go as high as 25%.
2. The maximum term of a repurchase agreement will be one (1) year.
3. A maximum of 10% of the portfolio may be invested in the instruments of any one
issuer with the exception of one (1) business day agreements and overnight sweep
agreements which may go as high as 25%.
H. Money Market Funds
1. A maximum of 80% of the portfolio may be invested in institutional money market
funds.
2. Money market funds must have an "AAA" rating from Moody's, Standard and Poor's
or Fitch.
3. A maximum of 25% of the portfolio may be invested in any one money market fund.
I. Corporate Obligations or Corporate Notes
1. A maximum of 25% of available funds may be invested in corporate obligations or
corporate notes.
2. A maximum of 5% of available funds may be invested in with any one issuer.
3. The maximum length of maturity of any Corporate Obligations or Corporate Notes is
five (5) years.
J. Commercial Paper
1. A maximum of 25% of available funds may be directly invested in Prime Commercial
Paper.
2. A maximum of 5% of available funds may be invested with any one issuer.
3. The maximum length to maturity for Prime Commercial Paper shall be 270 days from
the date of purchase.
K. Supranational Agencies
1. A maximum of 25% of available funds may be directly invested in Supranational
Agencies.
2. A maximum of 10% of available funds may be invested with any one issuer.
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3. The maximum length of maturity of any Supranational Agency is five (5) years.
L. Equities, Mutual Funds and/or ETFs
1. A maximum of 5% of available funds may be directly invested in eauities. mutual
funds and/or ETFs.
2. The County believes that to achieve the greatest likelihood of meeting the
investment objectives and the best balance between risk and return for optimal
diversification, assets will be invested in accordance with the targets for each
asset class as follows to achieve an average total annual rate of return that is equal
to or greater than the benchmark.
Asset Weightings
Asset Classes Range Target*
Domestic Equity
International (non -US) Equity
+/-1.5% 3.3%
+/-1.5 1.7%
*The targets are based on a strategic allocation of 66% in Domestic Equity and 34% in International
Equity. This may be adiusted from time -to -time to reflect the prevailing market.
W. RISK AND DIVERSIFICATION
Assets held shall be diversified to control the risk of loss resulting from the over concentration
of assets in a specific maturity, issuer, instrument, dealer, or bank through which these
instruments are bought and sold. Diversification strategies within the established guidelines
shall be reviewed and revised periodically as necessary by the appropriate management staff.
XI. AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS
The County shall only purchase securities from financial institutions which have offices
located within the State of Florida and are qualified as public depositories by the Treasurer
of the State of Florida, from primary securities brokers/dealers designated by the Federal
Reserve Bank of New York or from secondary brokers/dealers, with an office located in the
State of Florida. Such specified brokers/dealers must be reviewed and approved by the
Investment Committee and approved by the Board of County Commissioners.
Documented lists of the authorized financial institutions and brokers/dealers will be
developed and maintained by the Finance Director and approved by the Clerk of the Circuit
Court.
Investments in equities, mutual funds and/or ETFs are excluded from the broker/dealer
requirements.
The restriction on the secondary brokers/dealers with an office located in the State of Florida
does not apply to the external investment managers. The purpose is to provide greater
10
flexibility in seeking better pricing and optimize interest income to the County within the
guidelines set forth in this policy.
If at any time the Clerk of the Circuit Court is appropriately notified of any threat to the
integrity of the investment portfolio, proper security measures may be suggested and
implemented, and the Clerk of the Circuit Court shall have the option to further restrict
investment in selected instruments, to conform to the then -present market conditions.
Repurchase Agreements will be conducted through, and negotiated with primary securities
brokers/dealers, or secondary brokers/dealers, or Qualified Public Depository financial
institutions. A written Master Repurchase Agreement will be negotiated with any institutions
with which the County through the Clerk of the Circuit Court enters into a specific repurchase
agreement.
XII. THIRD PARTY CUSTODIAL AGREEMENTS
The Clerk of the Circuit Court will execute a Third Party Custodial safekeeping Agreement with
a commercial bank's trust department which is separately chartered by the United States
Government or the State of Florida. All securities purchased and/or collateral obtained by the
Clerk of the Circuit Court shall be properly designated as an asset of the County and held in
safekeeping by the trust department and no withdrawal of such securities, in whole or in part,
shall be made from safekeeping except by an authorized staff member. The Third Party
Custodial Safekeeping Agreement shall include letters of authority from the Clerk of the
Circuit Court, details as to responsibilities of each party, notification of security purchases,
sales, delivery, repurchase agreements, wire transfers, safekeeping and transaction costs,
procedures in case of wire failure or other unforeseen mishaps including liability of, each
party.
XIII. MASTER REPURCHASE AGREEMENT
The Clerk of the Circuit Court will require all approved institutions and dealers transacting
repurchase agreements to execute and perform as stated in the Master Repurchase
Agreement. All repurchase agreement transactions will adhere to requirements of the
Master Repurchase Agreement. The agreement shall specify that the underlying securities
have a market value of at least 103% of the principal balance of the investment. The market
value is to be determined on a monthly basis.
X44IV. BID REQUIREMENT
Although in most situations the competitive bid process shall be utilized, there is no
obligation to secure competitive bids from all financial institutions and dealer/brokers on the
approved list.
Rather a decision will be made by the Clerk of the Circuit Court through the Finance Director
as to the institutions that have been the most competitive over the preceding weeks and
these will be contacted for a bid.
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After the Clerk of the Circuit Court, through the Finance Director, has determined the
approximate maturity date based on the cash flow needs and market conditions and has
analyzed and selected one or more optimal types of investments, a minimum of three (3)
qualified banks and/or dealers will be contacted and asked to provide bids on the securities
in question.
1. Bids will be held in confidence until the highest bid is determined and awarded.
2. Documentation will be retained for all bids, with the winning bid clearly identified.
3. If for any reason the highest interest rate bid was not selected, then the reasons leading
to that decision will be clearly indicated on the bid form.
4. If the maturing investment in funds to be invested are from a certificate of deposit, the
present holder of the funds issuer of the CD will be one of the contacts made, subject to
the portfolio diversification requirements in this policy.
5. In certain circumstances where a dealer or bank informs the County of a potential sale
that must be completed within minutes of notification, the competitive bidding policy will
be waived. The Clerk of the Circuit Court will have final approval on these particular
transactions before they have been completed.
6. Investments inequities, mutual funds and/or ETFs are excluded from the minimum three
(3) bid requirement.
7. Notwithstanding the above, in order to afford financial institutions within St. Lucie County
opportunities to enhance the economy of the local area, certificates of deposit may be
purchased from an institution as described in Section VI.F provided that the following
additional conditions have been satisfied:
a. The institution, or a branch office, is located within the boundaries of St. Lucie
County.
b. The institution has the highest and best bid of all bidding institutions as described
in Section VI.F.
c. The institution awarded the bid is subject to the portfolio limitation requirements
and may not exceed said limitations.
d. Financial institutions included on the approved list must be Qualified Public
Depositories, as determined by the State of Florida.
XIV. INTERNAL CONTROLS
The Clerk of the Circuit Court shall exercise and monitor a set of internal controls to be
conducted through the Finance Director, Controls are designed to protect the County's funds and
ensure proper accounting and reporting of the securities transactions. The investment policy shall
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provide for review of such controls by independent auditors as part of any financial audit periodically
required of the unit of local government. Such internal controls shall consist of the following:
A. All securities purchased or sold will be transferred only under the "delivery versus
payment" (D.V.P.) method to ensure that funds or securities are not released until all
criteria relating to the specific transaction are met.
B. The Clerk of the Circuit Court is authorized to accept, on behalf of and in the name of St.
Lucie County, bank trust receipts or confirmations as evidence of actual delivery of the
obligation or securities in return for investment of funds.
C. Trust receipts or confirmations shall fully describe the various obligations or securities
held. The receipt or confirmation shall state that the investment is held in the name of St.
Lucie County.
D. Written documentation and/or confirmation of telephone transactions and wire transfers
will be maintained.
E. There will be adequate separation of duties with clear delegation of authority among
investment personnel.
F. Custodial safekeeping shall be properly utilized.
G. Operation review and performance evaluations and reporting, interim and annual, shall
be done by the Finance Director.
H. There will be an avoidance of no bearer -form securities.
I. There will be no physical delivery of securities.
J. There will be specific limitations regarding securities losses and remedial action shall be
taken as soon as possible.
K. A development of a wire transfer agreement with the custodial bank outlining the various
controls and security provisions for making and receiving wire transfers shall be made.
L. There is a prohibition of collusion between those making investment decisions and those
providing investment services.
M. Written dealer confirmation and monthly and/or quarterly custodial account statements
shall be maintained.
N. Investment policy shall be established by the Board of County Commissioners considering
the recommendations of the Investment Committee. All daily investment activity will be
coordinated and reviewed by the Finance Director. In the absence of the Finance Director
and Clerk of the Circuit Court investment activity must be approved by their designee and
later approved by the Finance Director or Clerk of the Court.
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O. The following positions are designated by the Clerk of the Circuit Court as having the
authority to initiate all investment activities:
1. Clerk of the Circuit Court
2. Finance Director
3. All other designees will be at the discretion of the Clerk of the Circuit Court.
All officials responsible for making investment decisions, or the Finance Director, shall
complete 8 hours of continuing education annually in subjects or courses of study related
to investment practices and products.
Q. Such additional internal controls as established by the Clerk of the Circuit Court.
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